Response 252752441

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Privacy Collection Statement

Do you agree to the Privacy Collection Statement?

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Yes, I agree and would like to make a confidential submission
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Your details

Name and contact details

Name
Dr Glenn Bowkett

I am submitting on behalf of

Submission for
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Myself
Business
Consumer association
Ticked Government department/agency
Industry association

Industry information - Government department/agency

Your industry

ANZSIC: div_name
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Agriculture, Forestry and Fishing
Mining
Manufacturing
Electricity, Gas, Water and Waste Services
Construction
Wholesale Trade
Retail Trade
Accommodation and Food Services
Transport, Postal and Warehousing
Information Media and Telecommunications
Financial and Insurance Services
Rental, Hiring and Real Estate Services
Professional, Scientific and Technical Services
Administrative and Support Services
Ticked Public Administration and Safety
Education and Training
Health Care and Social Assistance
Arts and Recreation Services
Other Services

Number of Employees

Number of Employees
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0-4
5-19
20-199
Ticked 200+

Jurisdiction

Jurisdiction
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Commonwealth
Ticked State/Territory
Local government

Do you use measurements for health, environment or justice purposes?

Measurements for health environment justice purposes
Please select one item
Ticked Yes
No

How many legal measuring instruments are used by your department/agency?

How many legal measuring instruments
Please select one item
1-10
11-50
51-100
Ticked 100+

Submission process

How would you like to submit your response

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Ticked Through the online survey
Emailing a confidential response

Policy objectives for legal metrology in Australia

Are the following policy objectives appropriate for legal metrology in Australia?

Supporting confidence in the measurement system
Please select one item
Ticked Yes No Unsure
Facilitating a level playing field for business
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Ticked Yes No Unsure
Consumer (or the broader term customer) protection
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Ticked Yes No Unsure
Supporting industry development and technology innovation
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Ticked Yes No Unsure

What is the relative importance of the following policy objectives for legal metrology in Australia?

Supporting confidence in the measurement system
Please select one item
Not important Somewhat important Ticked Highly important Unsure
Facilitating a level playing field for business
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Not important Somewhat important Ticked Highly important Unsure
Consumer (or the broader term customer) protection
Please select one item
Not important Ticked Somewhat important Highly important Unsure
Supporting industry development and technology innovation
Please select one item
Not important Ticked Somewhat important Highly important Unsure

Further comments

Further comments policy objectives
The maintenance of a legal framework to support legal measurement, dove tailed closely with physical measurement support/standards.

Are there any other policy objectives for legal metrology that would assist in delivering successful outcomes for Australian businesses and consumer?

Any other policy ogjectives
Education for person/bodies to appropriately work/operate within the legal measurement framework.

International cooperation and harmonisation

What should be the criteria for Australia's participation in the development of international documentary standards relevant to legal metrology?

Your response on criteria for Australia's participation in international standards
Australia should have expert representation in the development of international standards. This would be particularly relevant where the introduction of a new/revised standard would have more than minor changes/implications for those working within Australia. This call should probably come from experts in the field in consultation with NMI legal metrology.

What should be NMI’s approach to determining Australia’s pattern approval requirements where documentary standards from organisations such as the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC) more fully account for recent developments in technology and operation of measuring instruments than equivalent OIML standards?

NMI's approach to pattern approval requirements
As flexible as possible within a prescribed plicy framework. This is a delicate balance between: Best supporting Australian industry and requirements Advice of Experts in the field MOA requirements Economic benefits or costs. Often the NMAct has an all or nothing approach to equipment. It is fully Pattern Approved or it is just a recommendation. Maybe there is some more workable middle ground as well?

To what extent should NMI consider flexibility to allow for particular circumstances in Australia when adopting international standards for pattern approval?

Further comments
as above. If some flexibility can be built into a policy framework. Structured flexibility, if there is such a thing.

Principles-based approach to regulation

What are the key principles that should drive Australia’s regulatory approach to legal metrology?

Key principles
Support Business, Support government regulators, support a legal framework of measurement.

What level of guidance material, if any, should be available to ensure stakeholders have sufficient understanding of the policy objectives and outcomes being sought?

Level of guidance material
I think it is important that as many stakeholders as possible are made aware of pending changes/objectives. Initially at a point level, with ability to seek further infomation on request.

Risk-based approach to compliance monitoring

What are the appropriate factors to inform risk management related to setting priorities for regulation of legal metrology, including compliance and enforcement activity?

Factors to inform risk management
Yes, one obviously has to consider the risks associated with non-compliance. And this will help determine the effort that is put into each activity. In our case it is 100% proof. There is high risk, and large consequences in non-compliance. So we would expect support with appropirate legislation, a compliance framework and a checking activitity.

Regulatory approaches for legal metrology - Fit for purpose

How important is it that NMI considers the broader context of 'fit-for-purpose' when developing requirements/policies in relation to measurement?

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Not important
Somewhat important
Ticked Highly important
Unsure
Further comments
Again a balance between "fit-for-purpose" and risk-assessment. Often a one-size fits all approach doesn't work, but a framework with flexibility is better. A requirement for business may be at odds for a requirement in law enforcement. I.e a least measurement uncertainty doesn't work in a court of law where they want to know the worst case scenario.

How should NMI focus its regulatory activity in relation to conformity to type assessment?

Focus of regulatory activity in relation to conformity
I think this needs to be determined on a "fit-for-purpose" and risk assessment approach. What is the implications of an instrument not conforming to the original type? Therefore what level of activity do we have to put around it. I know this is difficult given there has to be a legal framework around it.

Regulatory approaches for legal metrology - Compliance and enforcement

How should NMI focus its compliance activities to ensure businesses are meeting their obligations under trade measurement law?

Comments-NMI focus of compliance activities
A structure of testing, but with random audits.

What are the appropriate circumstances for NMI to consider referral for prosecution as a regulatory response?

Appropriate circumstances for prosecution
Where there is intent to defraud. Where there is repeated negligance.